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2009 (1) TMI 27 - HC - Income Tax
Assessee under agreement provided advertisement services to its client-hotels - use of trademark/trade name were incidental - payments received were neither in the nature of royalty nor in the nature of fee for technical services - payments received were held by Tribunal as “business income” - no evidence brought by the Revenue to prove that the agreement was a fake - these are findings of fact - findings of the Tribunal are not perverse – no question of law arise – revenue’s appeal fails